Logging PIC 135

MSUDAWG said:
...Regardless if you are "sole manipulator" of the controls or not, 99.9% of companies after the one you work at now dont care if you were the sole manipulator, rather the Captain of record...
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Actually that is not true. While they are certainly in the minority, there are companies that understand and can use "sole manipulator" PIC time.

This means that if you didn't sign the logbook, ie: sign for the airplane, you are NOT the PIC. So if you have 200 hours of PIC time as the "sole manipulator" they know right off the bat that you were not the Captain and will want you to explain how you were the PIC...
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Again, if the sole manipulator PIC time is tracked seperately it won't be an issue. The applicant is not claiming that they were the PIC.
 
135.115
No pilot in command may allow any person to manipulate the flight controls of an aircraft during flight conducted under this part, nor may any person manipulate the controls during such flight unless that person is—

(a) A pilot employed by the certificate holder and qualified in the aircraft; or

(b) An authorized safety representative of the Administrator who has the permission of the pilot in command, is qualified in the aircraft, and is checking flight operations.
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To the OP: So how exactly are you the sole manipulator of the controls when 135.115 prevents you from manipulating the controls at all unless you are qualified (read 135.299 and 297 checked)?
 
skydisaster said:
135.115
No pilot in command may allow any person to manipulate the flight controls of an aircraft during flight conducted under this part, nor may any person manipulate the controls during such flight unless that person is—

(a) A pilot employed by the certificate holder and qualified in the aircraft; or

(b) An authorized safety representative of the Administrator who has the permission of the pilot in command, is qualified in the aircraft, and is checking flight operations.
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To the OP: So how exactly are you the sole manipulator of the controls when 135.115 prevents you from manipulating the controls at all unless you are qualified (read 135.299 and 297 checked)?
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this is the key here and what I was referring to. You can not touch the controls without an 135 ride
 
Legal Interpretation # 92-14

March 26, 1992

Mr. Michael G. Tarsa

Dear Mr. Tarsa:

Thank you for your letter of April 3, 1991, in which you ask
questions about logging pilot-in-command (PIC) and
second-in-command (SIC) time when operating under Part 135 of the
Federal Aviation Regulations (FAR). We apologize that staff
shortages, regulatory matters, and interpretation requests
received prior to yours prevented us from answering your
questions sooner.

Your letter presents the following scenario: a Part 135
certificate holder conducts operations in multiengine airplanes
under instrument flight rules (IFR). The operator has approval
to conduct operations without an SIC using an approved autopilot
under the provisions of FAR 135.105. The operator has assigned a
fully qualified pilot, who has had a Part 135 competency check,
to act as SIC in an aircraft that does not require two pilots
under its type certification. Although FAR 135.101 requires an
SIC for Part 135 operations in IFR conditions, the autopilot
approval is an exception to that requirement.

You correctly state that while the SIC is flying the airplane, he
can log PIC time in accordance with FAR 61.51(c)(2)(i) because he
is appropriately rated and current, and is the sole manipulator
of the controls. Additionally, he has passed the competency
checks required for Part 135 operations, at least as SIC.

You then ask two questions. The first asks whether the pilot
designated as PIC by the employer, as required by FAR 135.109,
can log PIC time while the SIC is actually flying the airplane.
The answer is yes.

FAR 1.1 defines pilot in command:

(1) Pilot in command means the pilot responsible for the
operation and safety of an aircraft during flight time.

FAR 91.3 describes the pilot in command:

(a) The pilot in command of an aircraft is directly
responsible for, and is the final authority as to, the
operation of that aircraft.

There is a difference between serving as PIC and logging PIC
time. Part 61 deals with logging flight time, and it is
important to note that section 61.51, Pilot logbooks, only
regulates the recording of:

(a) The aeronautical training and experience used to meet
the requirements for a certificate or rating, or the recent
flight experience requirements of this part.

FAR 61.51(c) addresses logging of pilot time:

(2) Pilot-in-command flight time. (i) A recreational,
private, or commercial pilot may log pilot-in-command time
only that flight time during which that pilot is the sole
manipulator of the controls of an aircraft for which the
pilot is rated, or when the pilot is the sole occupant of
the aircraft, or, except for a recreational pilot, when
acting as pilot-in-command of an aircraft on which more
than one pilot is required under the type certification of
the aircraft or the regulations under which the flight is
conducted.

(ii) An airline transport pilot may log as pilot in command
time all of the flight time during which he acts as pilot
in command.

(iii) (omitted).

(3) Second-in-command flight time. A pilot may log as
second in command time all flight time during which he acts
as second in command of an aircraft on which more than one
pilot is required under the type certification of the
aircraft, or the regulations under which the flight is
conducted.

As you can see, there are two ways to log pilot-in-command flight
time that are pertinent to your question. The first is as the
pilot responsible for the safety and operation of an aircraft
during flight time. If a pilot is designated as PIC for a flight
by the certificate holder, as required by FAR 135.109, that
person is pilot in command for the entire flight, no matter who
is actually manipulating the controls of the aircraft, because
that pilot is responsible for the safety and operation of the
aircraft.

The second way to log PIC flight time that is pertinent to your
question is to be the sole manipulator of the controls of an
aircraft for which the pilot is rated, as you mention in your
letter. Thus, a multiengine airplane flown under Part 135 by two
pilots can have both pilots logging time as pilot in command when
the appropriately rated second in command is manipulating the
controls.

We stress, however, that here we are discussing logging of flight
time for purposes of FAR 61.51, where you are keeping a record to
show recent flight experience or to show that you meet the
requirements for a higher rating. Your question does not say if
the second pilot in your example is fully qualified as a PIC, or
only as an SIC. This is important, because even though an SIC
can log PIC time, that pilot has not qualified to serve as a PIC
under Part 135.

An example of this difference is FAR 135.225(d), which raises IFR
landing minimums for pilots in command of turbine powered
airplanes flown under Part 135 who have not served at least 100
hours as PIC in that type of airplane. Served and logged are not
the same in this context, and no matter how the SIC logs his
time, he has not served as a PIC until he has completed the
training and check rides necessary for certification as a Part
135 PIC.

Approval for single pilot operations with use of an operative
approved autopilot system under FAR 135.105 gives an operator an
additional option in the conduct of operations. It does not
mandate that all future flights be conducted in that manner. The
operator can elect to fly trips with two pilots, as is otherwise
required for flight in IFR conditions under FAR 135.101, using
the second in command instead of the autopilot.

Your second question asks if, under the circumstances given
above, the SIC can log time as SIC when the designated pilot in
command is flying the aircraft. The answer is yes, as long as
the certificate holder is using the SIC as a crewmember instead
of exercising the autopilot authorization. In other words, the
certificate holder elects not to conduct an IFR flight using the
single pilot with a functioning autopilot option, but rather
conducts an IFR flight using two qualified pilots. The two
pilots are then "required by the regulations under which the
flight is conducted", FAR 61.51(c)(3), and the assumption is that
the second pilot (SIC) will function as a required crewmember,
and SIC time may validly be logged. However, if for some reason
another qualified pilot "rides along" and does not function as a
crewmember, then second-in-command time may not be validly
logged.

This interpretation has been prepared by Arthur E. Jacobson,
Staff Attorney, Operations Law Branch, Regulations and
Enforcement Division; Richard C. Beitel, Manager. It has been
coordinated with the Manager, Air Transportation Division, and
the Manager, General Aviation and Commercial Division, Flight
Standards Service.

We hope this satisfactorily answers your questions.

Sincerely,

/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division
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skydisaster said:
135.115
No pilot in command may allow any person to manipulate the flight controls of an aircraft during flight conducted under this part, nor may any person manipulate the controls during such flight unless that person is—

(a) A pilot employed by the certificate holder and qualified in the aircraft; or

(b) An authorized safety representative of the Administrator who has the permission of the pilot in command, is qualified in the aircraft, and is checking flight operations.
-------------

To the OP: So how exactly are you the sole manipulator of the controls when 135.115 prevents you from manipulating the controls at all unless you are qualified (read 135.299 and 297 checked)?
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It is important to remember that a pilot is sometimes allowed to log PIC time without being qualified to act as the PIC of a flight.

1. You don't need 135 PIC checks to be an SIC under 135
2. An SIC that is type rated in the airplane can log PIC time when he is the sole manipulator of the controls (and he does NOT have to be PIC qualified to do so).
 
Steve, correct me if I am wrong, but I don't see that the OP is part 135 SIC qualified in the airplane either. If he is not qualified under part 135, he cannot touch the controls on a 135 leg. If he cannot touch the controls, he cannot be sole manipulator.
 
skydisaster said:
Steve, correct me if I am wrong, but I don't see that the OP is part 135 SIC qualified in the airplane either.
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I took the original post to mean that he was not PIC qualified. The SIC qualification is pretty simple, and I would assume that he has had the required check or he wouldn't be flying the airplane in the first place. I could be wrong though, but I'm guessing that the type rating was received under the company's 135 training program.
If he is not qualified under part 135, he cannot touch the controls on a 135 leg. If he cannot touch the controls, he cannot be sole manipulator.
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I fully agree, as long as you are saying "If he is not qualified as SIC under part 135...". He does not have to be PIC qualified to be sole manipulator.
 
SteveC said:
I took the original post to mean that he was not PIC qualified. The SIC qualification is pretty simple, and I would assume that he has had the required check or he wouldn't be flying the airplane in the first place. I could be wrong though, but I'm guessing that the type rating was received under the company's 135 training program.

I fully agree, as long as you are saying "If he is not qualified as SIC under part 135...". He does not have to be PIC qualified to be sole manipulator.
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Agreed! I read it as he had gotten a type rating in his own, and was just building to get to the left seat. It sounds like we are on the same page though.
 
SteveC said:
I took the original post to mean that he was not PIC qualified. The SIC qualification is pretty simple, and I would assume that he has had the required check or he wouldn't be flying the airplane in the first place. I could be wrong though, but I'm guessing that the type rating was received under the company's 135 training program.

I fully agree, as long as you are saying "If he is not qualified as SIC under part 135...". He does not have to be PIC qualified to be sole manipulator.
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Agreed! I read it as he had gotten a type rating in his own, and was just building to get to the left seat. It sounds like we are on the same page though.
 
What about relief officers flying in the left seat? They can't log PIC even though the real PIC (the Captain) isn't even present on the flight deck. He's sound asleep in the bunk. They are acting as PIC a heck of a lot more than some type rated copilot manipulating the controls with the real PIC still in the left seat, and yet they still don't log it as PIC.

Bottom line is unless you sign the flight release/logbook and are designated PIC by your company, you are NOT the PIC no matter what FAR technicality you are trying to justify it under.
 
A-300F4-622R said:
What about relief officers flying in the left seat? They can't log PIC even though the real PIC (the Captain) isn't even present on the flight deck. He's sound asleep in the bunk. They are acting as PIC a heck of a lot more than some type rated copilot manipulating the controls with the real PIC still in the left seat, and yet they still don't log it as PIC.
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You're talking about airline flying, correct? Not my area of expertise.

Bottom line is unless you sign the flight release/logbook and are designated PIC by your company, you are NOT the PIC no matter what FAR technicality you are trying to justify it under.
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You're right, the pilot in that situation is not the legal PIC in charge of the flight. Still doesn't mean that they can't log PIC time as long as they understand the reason why they are allowed to log it, can separate that time from "true" PIC time when needed, and do not try to misrepresent that time.

While I understand the fairly common feeling that you express, I disagree with telling others that THEY should not log perfectly legal, and well understood in SOME aviation circles, time that can help them along their journey. I think it does a disservice that is unwarranted. You will notice that the method that I advocate is intended to avoid any possible misrepresentation of what I call "Part 61 PIC" as being "true" PIC time, so there is no attempt to pawn it off as something it is not.

I work in the 135 world. I've been told numerous times that the airlines do not recognize the sole manipulator PIC time when analyzing a pilot's log book, so I suppose if someone is only interested in 121 flying there may not be any reason to log "61-PIC". *shrug* That's fine and understandable. On this side of the field though there are times (in the 135 world) where 61-PIC is useful, both to the pilot and to the company. So again I say to the up-and-coming pilots - understand the difference between BEING the PIC, and the legal times that you can LOG PIC (and I recommend keeping track of the two kinds of PIC time differently), and use the knowledge to prove to your prospective employer that you are in the minority that understands this area of the regulations.
 
SteveC said:
You're talking about airline flying, correct? Not my area of expertise.



You're right, the pilot in that situation is not the legal PIC in charge of the flight. Still doesn't mean that they can't log PIC time as long as they understand the reason why they are allowed to log it, can separate that time from "true" PIC time when needed, and do not try to misrepresent that time.

While I understand the fairly common feeling that you express, I disagree with telling others that THEY should not log perfectly legal, and well understood in SOME aviation circles, time that can help them along their journey. I think it does a disservice that is unwarranted. You will notice that the method that I advocate is intended to avoid any possible misrepresentation of what I call "Part 61 PIC" as being "true" PIC time, so there is no attempt to pawn it off as something it is not.

I work in the 135 world. I've been told numerous times that the airlines do not recognize the sole manipulator PIC time when analyzing a pilot's log book, so I suppose if someone is only interested in 121 flying there may not be any reason to log "61-PIC". *shrug* That's fine and understandable. On this side of the field though there are times (in the 135 world) where 61-PIC is useful, both to the pilot and to the company. So again I say to the up-and-coming pilots - understand the difference between BEING the PIC, and the legal times that you can LOG PIC (and I recommend keeping track of the two kinds of PIC time differently), and use the knowledge to prove to your prospective employer that you are in the minority that understands this area of the regulations.
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Yes I'm talking about 121 flying and in the 135 that I worked for, there was only one PIC. They can log whatever they feel like they can get away with. Be prepared to explain and justify the how and why you logged what you logged at an interview. The interviewer might take a different view.
 
A-300F4-622R said:
Yes I'm talking about 121 flying and in the 135 that I worked for, there was only one PIC. They can log whatever they feel like they can get away with. Be prepared to explain and justify the how and why you logged what you logged at an interview. The interviewer might take a different view.
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I keep a separate column in my logbook. "61 PIC" is the label, and it is for sole manipulator, not acting PIC time. Makes it simple to add it to either the PIC or SIC column depending upon who is asking the question and how THEY want to see that time counted.

Personally that keeps my stress level kind of low when it comes to this topic.
 
A-300F4-622R said:
Yes I'm talking about 121 flying and in the 135 that I worked for, there was only one PIC. They can log whatever they feel like they can get away with. Be prepared to explain and justify the how and why you logged what you logged at an interview. The interviewer might take a different view.
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Different view? The regulation is clear as day.

No one is advocating the OP try claim he has hundreds of hours of Multi Engine PIC, but if he is legal to log it then why not?

At my old company, we flew a single engine, single pilot turbo prop. The FOs were required by regulation on the occupied legs, but they were not required crew members on the empty legs. The only way they could log anything for those flights was if they flew the leg and logged 61.51 PIC.

I don't understand the problem?
 
A-300F4-622R said:
What I mean is that if people are having to use every technicality to try and justify themselves as PIC, then they shouldn't log it. Because even if there are circumstances where you may legally log PIC, you are not truly the PIC.
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I have a little difficulty in referring to a rule that has been absolutely clear for more than 40 years and has its roots going back a few decades before that as a "technicality." OTOH, "technicality" and "loophole" tend to be used to refer to things we personally disagree with, so it' hardly ab objective assessment of anything. So let;s change your statement to make it a little more objective and see how it sounds.

==============================
What I mean is that if people are having to use the rules about logging PIC very technicality to try and justify themselves logging as PIC, then they shouldn't log it.
==============================

Sounds a bit silly that way, doesn't it? Sounds a bit like a recommendation to not follow the rules you don't like. I'm not sure I'd want to fly for or in a carrier with that philosophy.
 
MidlifeFlyer said:
I have a little difficulty in referring to a rule that has been absolutely clear for more than 40 years and has its roots going back a few decades before that as a "technicality." OTOH, "technicality" and "loophole" tend to be used to refer to things we personally disagree with, so it' hardly ab objective assessment of anything. So let;s change your statement to make it a little more objective and see how it sounds.

==============================
What I mean is that if people are having to use the rules about logging PIC very technicality to try and justify themselves logging as PIC, then they shouldn't log it.
==============================

Sounds a bit silly that way, doesn't it? Sounds a bit like a recommendation to not follow the rules you don't like. I'm not sure I'd want to fly for or in a carrier with that philosophy.
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Log what you want, but you are NOT the real PIC and you know it and so does anyone that would audit your logbook during an interview.
 
I just don't understand why people care so much about this flight time, is it legal, sure. If you're not signing for the airplane and acting as the PIC, it's not quality PIC time.
 
jhugz said:
I just don't understand why people care so much about this flight time, is it legal, sure. If you're not signing for the airplane and acting as the PIC, it's not quality PIC time.
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Did you not read any of Steve's posts?

Sometimes, the time helps, especially with insurance minimums. If it might help, keep track of it.

Makes sense to me.
 
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